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2 <br /> <br />3. Page 13, Post-Construction Runoff. Blanding’s turtles, a protected state-listed threatened <br />species, have been documented within the project area. Stormwater features may be colonized <br />by Blanding’s turtles in the area, therefore we recommend incorporating measures to avoid <br />impacting this species into stormwater management. In years when the stormwater features <br />will be dredged to remove excess sediment, please draw down water levels by September 15th <br />in order to allow turtles to find overwintering habitat elsewhere. <br />4. Page 13, Post-Construction Runoff. We recommend that BWSR-approved, weed-free, native <br />seed mixes be used to the greatest degree possible in stormwater features in order to provide <br />pollinator habitat. <br />5. Page 13, Post-Construction Runoff. The planned increase in impervious surfaces will also <br />increase the amount of road salt used in the project area . Chloride released into local lakes and <br />streams does not break down, and instead accumulates in the environment, potentially <br />reaching levels that are toxic to aquatic wildlife and plants. Consider promoting local business <br />and city participation in the Smart Salting Training offered through the Minn esota Pollution <br />Control Agency. There are a variety of classes available for road applicators, sidewalk <br />applicators, and property managers. More information and resources can be found at this <br />website. Many winter maintenance staff who have attended the Smart Salting training — both <br />from cities and counties and from private companies — have used their knowledge to reduce <br />salt use and save money for their organizations. <br />We also encourage cities and counties to consider how they may participate in the Statewide <br />Chloride Management Plan and provide public outreach to reduce the overuse of chloride. Here <br />are some educational resources for residents as well as a sample ordinance regarding chloride <br />use. <br />6. Page 20, Rare Features. This section of the EAW lists the rare species identified in the DNR <br />Natural Heritage Review, but does not include or discuss DNR requirements regarding these <br />species. The statement that, “There are no state listed species within the project site” is <br />incorrect. The Natural Heritage Review letter has concerns about two state-listed species that <br />may occur within the site. The lack of known occurrences within the project boundary does not <br />mean that these species do not use the area. Minnesota’s Endangered Species Statute <br />(Minnesota Statutes, section 84.0895) and associated Rules (Minnesota Rules, part 6212.1800 <br />to 6212.2300 and 6134) prohibit the take of threatened or endangered species without a <br />permit. <br /> Swamp Blackberry (Rubus semisetosus), a state-listed endangered species, has been <br />documented in the vicinity of the project. A qualified surveyor needs to conduct a <br />botanical survey if any shrub removal is associated with the proposed project . Surveys <br />must be conducted by a DNR approved surveyor (see attached list) and follow the standards <br />contained in the Rare Species Survey Process and Rare Plant Guidance. Project planning <br />should take into account that any botanical survey needs to be conducted during the <br />appropriate time of the year, which may be limited. Please consult with the NH Review <br />Team (Reports.NHIS@state.mn.us) regarding this process.